Apple Inc. v. Samsung Electronics Co., Ltd.
678 F. App'x 1012
| Fed. Cir. | 2017Background
- Apple sued Samsung for design-patent infringement; the dispute reached the Federal Circuit and then the Supreme Court on damages under 35 U.S.C. § 289.
- The Supreme Court held that “article of manufacture” in § 289 can be either a finished product or a component of a multicomponent product, and remanded for further proceedings to identify the relevant article and calculate profits accordingly.
- The Federal Circuit had previously affirmed a damages award based on Samsung’s entire phones as the relevant articles of manufacture.
- On remand to the Federal Circuit, Apple argued Samsung never identified any component other than the entire phone at trial, so the jury finding should stand without more proceedings.
- Samsung argued the district court’s § 289 instruction was insufficient under the Supreme Court’s guidance and asked for a new damages trial so the court could identify the proper article(s) of manufacture and resolve remaining issues.
- The Federal Circuit declined to resolve the record-based jury-instruction dispute itself and remanded to the district court to consider the trial record and decide whether further proceedings (including a new damages trial) are necessary.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper interpretation/application of "article of manufacture" under § 289 | Apple: Samsung failed to identify any component at trial; record supports only whole phones as the article(s) | Samsung: Court instruction should have acknowledged possible component-level articles; remand for new trial needed | Court: Supreme Court clarified term can include components; remanded to district court to evaluate the trial record and determine next steps |
| Whether Federal Circuit can resolve damages issue now or must remand | Apple: Affirm damages now based on trial record | Samsung: Remand for new damages trial to apply Supreme Court guidance | Court: Remand to district court to consider record and decide if new trial or other proceedings required |
Key Cases Cited
- Samsung Elecs. Co. v. Apple Inc., 137 S. Ct. 429 (2016) (Supreme Court: “article of manufacture” may be component or end product and remanded for further proceedings)
- Apple Inc. v. Samsung Electronics Co., 786 F.3d 983 (Fed. Cir. 2015) (prior Federal Circuit decision under review)